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policies and processes and are based on the laws and regulations for money
laundering prevention regarding the knowledge of the client and/or supplier,
collecting the necessary and substantial information to prove our operations’
transparency and complying with the required applicable laws. As a condition
to maintain business relationships with La Comer, suppliers must adhere
to this Code of Ethics and the Company’s internal policies, comply with its
provisions and supervise its compliance, through the means set out by La
Comer.

4.2.3 Zero Tolerance
In order to maintain total business independence and avoid harmful practices
by our staff in any business relationship, the Company’s members will not
accept or provide gifts or valuable items (including invitations or gratuities of 4.3 RELATIONS WITH SHAREHOLDERS
any kind for recreational activities regardless of the means as well as to leisure
trips, sporting and cultural events, among others) from current and/or potential AND INVESTORS
CODE OF ETHICS RESPECT IS THE GOLDEN RULE
clients or suppliers. Similarly, no family member of our employees should accept One of the main responsibilities of the Company’s members is to protect the
or provide gifts, services, loans or preferential treatment from third parties in equity of our shareholders and investors, maintaining a solid and competitive
exchange for business relationships with the Company, whether past, present position in their relationships in the short, medium and long term, generating
or future. the value they expect.

All employees have the strict obligation to reject any gift and in the event that 4.3.1 Shareholder Value
its return is not feasible, it must be delivered to the Human Resources area, The protection of shareholders’ equity is the main responsibility of the
along with a description of facts, in accordance with the applicable policy. Company’s executives. The creation of sustainable value for shareholders
must be part of the business philosophy, striving to constantly increase
Moreover, it is forbidden to accept or request compensation, loans or gratuities short-term revenues without losing sight of or compromising them in the
from goods or services’ suppliers, from potential suppliers or from any other long term.
interested party with whom there are commercial relationships or may exist
in the future; making payments outside the contracted terms will not be 4.3.2 Public Information
accepted under any circumstances. Financial information and all records must reflect the accurate situation of
the Company and be filed under current International Financial Reporting
This Code does not prohibit the receipt or offer of articles that are acceptable Standards, as they are the foundation for decision-making. La Comer, S.A.B.
as a common practice to promote a supplier’s services or products or that La de C.V. is a public company that actively participates in the national financial
Comer grants to the public, such as T-shirts, mugs, pens, calendars, planners, market, both of debt and equity.
stationary, among others, as long as they do not have a substantial value, and
do not influence an employee’s performance of their functions within the The Company is obliged to comply in a timely manner with the legal
Company or are interpreted as a conflict of interest. requirements established by the securities commissions of the markets in
which it participates and with the contracts with financial institutions. Only
It is forbidden for all employees to accept invitations from suppliers, clients, authorized personnel may publish materials, impart lectures, grant press
financial institutions or competitors, to attend shows or sporting events, as interviews, or make public presentations on Company-related matters.
well as gratuities or compensation of any kind. In the case of invitations for
commercial purposes such as presentations and conferences, these must be Making false or misleading statements, as well as hiding information from
authorized by the General Management before being accepted and travel management, shareholders, investors, external or internal auditors or a
expenses will be covered by the corresponding subsidiary of La Comer. Company regulator, constitute serious offenses that will lead to sanctions.

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